The Compliance Life details the journey to and in the role of a Chief Compliance Officer. How does one come to sit in the CCO chair? What skills does a CCO need to navigate the compliance waters in any company successfully? What are some of the top challenges CCOs have faced, and how did they meet them? These questions and many others will be explored in this new podcast series. Over four episodes each month on The Compliance Life, I visit with one current or former CCO to explore their journey to the CCO chair. This month, I am joined by Scott Garland, Managing Director at AMI. Scott came to AMI from the DOJ, where he held the role of Professional Responsibility Officer. As he described, it was akin to a CCO role for the US Attorney’s Office for Massachusetts.
Some of the key lessons Garland learned in the role of Professional Responsibility Officer, which apply to the skill set needed to be a CCO, include; (1) Always do the right thing, but it is not always obvious what that is; (2) the issue you are presented might not be the real issue, or the sole real issue, (3) being calm and nonjudgmental helps people open up, (4) try and balance analysis with action, pragmatism with principles, using tenets of risk management, (5) craft advice that is simple, clear, and unambiguous. (6)Do not just say what not to do; also say what to do and when to come back for more help, (7) admit mistakes as soon as possible, and (8) good people make mistakes. Most people will forgive a mistake if done unintentionally; you are forthright about it and try to fix it.
Garland recently joined Affiliated Monitors, Inc. as Managing Director – Sanctions, Cyber, Fraud, and Ethics Compliance & Monitoring. One of the reasons he did so was to help companies strengthen their compliance operations in these areas in a couple of areas. The first is before the government comes knocking by proactively assessing a company’s compliance operations and ethical culture and recommending improvements. The second is after the government knocks, acting as an independent monitor of the company’s compliance with a plea agreement, settlement agreement, consent decree, court or administrative order; emphasize not playing gotcha or playing the blame game, but rather with helping the company improve through lasting change.
Resources
Scott Garland’s Profile on AMI
